Audit 370038

Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.033, 84.268 Finding Type: Material Weakness in Internal Control over Compliance; Material Noncompliance Criteria: To participate in the Title IV programs, an organization must demonstrate financial responsibility to the U.S. Department of Education (ED). ED considers an organization to be financially responsible if it has a Composite Score of its primary Reserve Ratio, Equity Ratio and Net Income Ratio of at least 1.0 or satisfies one of the alternative options (Letter of Credit Alternative or Provisional Certification Alternative) to meet the financial responsibility requirements (34 C.F.R. § 668.172). Condition: The Organization did not meet the financial responsibility Composite Score threshold for the fiscal year ended December31, 2024. - Cause: As a result of the prior period adjustment to the 2023 financial statements, net assets were significantly reduced which negatively affected the Organization's 2024 Composite Score. Effect or Potential Effect: The Organization's calculated Composite Score for the fiscal year ended December 31, 2024 was below 1.0. An organization that does not meet the Composite Score threshold may be deemed as not financially responsible by ED. Questioned Costs: There are no questioned costs associated with this finding. Repeat Finding: Not a repeat finding. Recommendation: The Organization should take steps to monitor its operating budget and ensure that it meets the necessary financial ratio requirements. Views of Responsible Officials: The Organization concurs with this finding and has procedures in place as outlined in the Corrective Action Plan to ensure compliance with requirements. 40

Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.033, 84.268 Finding Type: Significant Deficiency in Internal Control over Compliance; Other Matters Criteria: Organizations are required to report Campus and Program level changes in a student's enrollment information to the National Student Loan Data System (NSLDS). Organizations must review, update, and verify student enrollment statuses, program information, and effective dates and report this information to NSLDS in an accurate and timely manner. Changes to enrollment status for less than half-time, graduated, or withdrawn must be reported within 30 days; however, if a roster file is expected within 60 days, the organization may provide the updated data on that roster file (34 C.F.R. § 690.83(b)(2) and 34 C.F.R. § 685.309(b)). Condition: The Organization reported enrollment status changes to NSLDS in an untimely manner for several students. Cause: In these cases, it appears that the Organization's procedures for updating enrollment status changes to NSLDS in a timely manner were not properly followed. Effect: Information reported to NSLDS was compared to information from the students' files for students from our file testing sample who had a reduction or increase in attendance levels, graduated, withdrew, or enrolled but never attended during the examination period. For ten of the 36 student status updates tested (nonstatistical sample), the following untimely student status updates were noted: Date of Next Roster Certification Student Status Determination Submittal Date Al Graduated 12/14/24 February 2025 06/13/25 All Withdrawal 08/17/24 October 2024 05/14/25 A16 Withdrawal 12/14/24 February 2025 06/13/25 A18 Graduated 12/14/24 February 2025 06/13/25 A23 Graduated 12/14/24 February 2025 04/14/25 A32 Graduated 04/20/24 June 2024 10/14/24 A35 Withdrawal 04/18/24 June2024 12/13/24 N2 Graduated 12/14/24 February 2025 06/13/25 NS Graduated 05/18/24 August2024 10/14/24 N9 Graduated 12/14/24 February 2025 06/13/25 The overall rate for this finding is 27.8% (10/36) Questioned Costs: There are no questioned costs associated with this finding. Repeat Finding: This is a repeat finding from the prior year (Finding 2023-002). Recommendation: The Organization should take steps to ensure that its procedures to submit information to NSLDS in a timely manner are strictly followed. Views of Responsible Officials: The Organization concurs with this finding and has procedures in place as outlined in the Corrective Action Plan to ensure compliance with requirements.